Description

This course will discuss key US international tax and Transfer Pricing (TP) issues that we have often seen in the Cannabis industry, along with structure planning ideas.

Target Audience

CPAs, Attorneys, Enrolled Agents, Financial Professionals, and anyone interested in the fundamentals of this industry.

Course Objectives

• Determine: what potential International tax and TP issues are commonly associated with cannabis industry
• Recognize: US rules relating to international tax and TP
• Identify: potential structure planning ideas

Subjects

• PFIC
• CFC - Subpart F & 280E; GILTA & 280E
• Inversions
• Common TP issues and planning ideas

Advanced Preparation

Working knowledge of Cannabis taxation.